Privacy Policy

1. Definitions

Personal Data: Any information that identifies or makes identifiable a natural person.

Special Category Personal Data: Data relating to a person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing and appearance, association, foundation or union membership, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.

Related Person: A natural person whose personal data is processed.

Applicant: Refers to the relevant person who applies to ESG Yazılım within the scope of the Law.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data, and who is responsible for the establishment and management of the data recording system.

Data Processor: The natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller.

Explicit Consent: Consent given with free will based on information regarding a specific matter.

Processing of Personal Data: Includes all kinds of operations performed on data, such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing the use of personal data, whether wholly or partially by automatic means or by non-automatic means provided that it is part of any data recording system.

Anonymization: Personal data is rendered in such a way that it can no longer be associated with an identified or identifiable natural person, even when matched with other data.

Board: Refers to the Personal Data Protection Board.

Board: Refers to the Personal Data Protection Board.

Law/KVKK: Refers to the Law on the Protection of Personal Data No. 6698 dated March 24, 2016, published in the Official Gazette No. 29677 dated April 7, 2016.

2. Information About Privacy

ESG Yazılım agrees and declares that it will not disclose, distribute, show, give, lease, sell, or otherwise transfer any of your personal information to any third party without your prior consent or unless legally obligated to disclose such information due to a court order or any other legal process, and that it will take the necessary care to protect it.

3. Information About the Protection of Personal Data

As ESG Yazılım, we attach utmost importance to the security of your personal data. With this awareness, we attach great importance to the processing and storage of all kinds of personal data belonging to visitors and members who benefit from our services, and all individuals related to ESG Yazılım, in accordance with the Law No. 6698 on the Protection of Personal Data ("Law"). With full awareness of our responsibility arising from the Law, as the "Data Controller" in the manner defined in the Law, we process your personal data as explained below and within the limits mandated by the legislation.

4. Collected and Processed Personal Data

The term "Personal Data", as used in this Policy text, means information that identifies you, such as your first name, middle name, last name, date of birth, landline phone number, mobile phone number, email address, residential address, and data obtained from social media accounts that are publicly available and/or explicitly declared by the user or linked by their own will in the system. ESG Yazılım reserves the right to request other data and information for reasons arising from its services. The collected and processed data of our visitors and members;

a) Our Visitors

Visitors are individuals who follow the platform without becoming members of ESG Yazılım's platforms. The personal data of our visitors, listed below, is processed. No data of visitors who do not create a membership is processed by the platform. The identity and contact information of visitors who do not create a membership are not processed; only cookies and traffic data (IP, browser information, etc.) are processed. In this regard, Our Cookie Policy you can review.

b) Our members

Our members are individuals who have a membership account by accepting the membership terms on the platforms belonging to ESG Yazılım. The personal data of our members, listed below, is processed.

Your Identity Information: your name, surname, gender and age information, TCKN

Your Contact Information: your mobile phone number, your physical address, your email address,

Your Member Transaction Information: bank account number, transaction history information, your requests and complaints,

Your Transaction Security Information: IP address information, password and passphrase information, cookie information,

Your Legal Transaction Information: information in correspondence with authorized persons, institutions, and organizations, information in legal case and execution files, information from legal requests for information,

Your Auditory Recording Information: voice recordings in case of your call with the call center

5. Purposes of Processing Personal Data

Your personal data will be processed in accordance with the principles set forth in Article 4 and the personal data processing conditions specified in Articles 5 and 6 of the Law, for the purposes of fulfilling the services we provide to our visitors and members in accordance with the requirements of the contract and technology, providing support services related to the services, managing our member relations processes, responding to your requests and complaints, carrying out the necessary work by our relevant business units for the execution of the commercial activities carried out by our Company, and managing the related business processes. As long as you continue to use the platforms belonging to ESG Yazılım with member status, your personal data may be processed by being updated. Additionally, your personal data may be processed when you use the platform to use ESG Yazılım services, when you visit ESG Yazılım offices or our websites, and when you participate in organizations organized by ESG Yazılım. The purposes of processing the personal data of our members are;

Identity, communication, and member transaction information are automatically collected and processed electronically from our members via the website/mobile application within the scope of the membership agreement for the following purposes.

• Carrying out processes related to the establishment and execution of the contract,
• Carrying out and overseeing financial and accounting processes,
• Execution and supervision of the company's business activities,
• Execution of invoicing processes,
• Completion of payment transactions via website/mobile applications and verification of the identity information of the transactor,
• If you provide your explicit consent, it may be used in various marketing and advertising activities, and activities aimed at providing you with a better experience and increasing your satisfaction will be carried out,
• To increase user satisfaction, to recognize users and use them in user environment analysis, to carry out activities for the development and improvement of the services offered by our Company,
• Execution of strategic analysis studies,
• conducting communication activities,
• If you have given your explicit consent, providing you with information about developments, opportunities, and innovations related to ESG Yazılım,
• evaluation of your requests, complaints, and suggestions regarding the platform,
• Execution of information security processes,
• Ensuring the security of ESG Yazılım's operations,
• Ensuring that activities are carried out in accordance with legislation,
• Tracking and execution of legal affairs,
• Authorized person, providing information to public institutions and organizations.

Transaction security information is automatically collected and processed electronically from our members via the website/mobile application under the membership agreement for the following purposes.

• Carrying out processes related to the establishment and execution of the contract,
• Execution and supervision of the company's business activities,
• Completion of payment transactions via website/mobile applications and verification of the identity information of the transactor,
• If you provide your explicit consent, it may be used in various marketing and advertising activities, and activities aimed at providing you with a better experience and increasing your satisfaction will be carried out,
• To increase user satisfaction, to recognize users and use them in user environment analysis, to carry out activities for the development and improvement of the services offered by our Company,
• Execution of information security processes,
• Ensuring the security of ESG Yazılım's operations,
• Ensuring that activities are carried out in accordance with legislation,
• Authorized person, providing information to institutions and organizations.

Legal transaction information is collected and processed automatically from our members via the website/mobile application under the membership agreement for the following purposes in an electronic environment.

• Carrying out processes related to the establishment and execution of the contract,
• Execution and supervision of the company's business activities,
• evaluation of your requests, complaints, and suggestions regarding the platform,
• Execution of information security processes,
• Ensuring the security of ESG Yazılım's operations,
• Ensuring that activities are carried out in accordance with legislation,
• Tracking and execution of legal affairs,
• Authorized person, providing information to institutions and organizations.

Auditory recording information is collected and processed for the following purposes when you contact the call center.

• Carrying out processes related to the establishment and execution of the contract,
• conducting communication activities,
• If you provide your explicit consent, it may be used in various marketing and advertising activities, and activities aimed at providing you with a better experience and increasing your satisfaction will be carried out,
• If you have given your explicit consent, providing you with information about developments, opportunities, and innovations related to ESG Yazılım,
• Identifying platform users, conducting activities for user environment analysis, and performing survey studies electronically and/or physically through contracted organizations within this scope,
• evaluation of your requests, complaints, and suggestions regarding the platform,
• Ensuring the security of ESG Yazılım's operations,
• Ensuring that activities are carried out in accordance with legislation,
• Tracking and execution of legal affairs,
• Authorized person, providing information to institutions and organizations.

However, if you give us your consent for the processing of your personal data, said personal data will be processed within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, for the purposes of customizing our services in line with your needs and requests, measuring your satisfaction with our services, developing and diversifying our services in line with your requests and needs, providing information about the activities of the company and its affiliated companies and subsidiaries, conducting marketing analysis studies, and carrying out personalized campaigns, advertisements, and promotions.

If explicit consent is not given or is withdrawn, the relevant data will continue to be processed only within the scope of the necessary legal basis; it will not be processed for purposes such as marketing or analysis.

6. Method and Legal Basis for Collection of Personal Data

Your personal data is collected for the purpose of providing the services we offer as ESG Yazılım in accordance with the specified legal framework, and for ESG Yazılım to fully and accurately fulfill its contractual and legal obligations, in any verbal, written, or electronic, physical medium, in line with the purposes stated above. Your personal data may be collected through verbal, written, or electronic means via ESG Yazılım units and offices, website, social media platforms, mobile applications, and similar tools, by automatic or non-automatic methods, although it may vary depending on the services provided by ESG Yazılım and ESG Yazılım's commercial activities.

• Based on the legal ground that it is explicitly provided for in the legislation to which our company is subject; fulfilling our obligations arising from legislation, primarily activities aimed at ensuring the security of operations on platforms belonging to ESG Yazılım, conducting information security processes, and ensuring that activities are carried out in accordance with legislation,
• Based on the legal ground that the processing of your personal data is necessary for the establishment or performance of a contract; carrying out activities for the establishment of contracts concluded through our platform, carrying out activities for the execution of your payment transactions, carrying out and auditing the company's business activities, evaluating your requests, complaints, and suggestions regarding our services, carrying out and auditing financial and accounting processes, carrying out communication activities,
• Fulfillment of legal obligations stipulated in the secondary legislation to which ESG Yazılım is subject and/or in decisions, guidelines, and guides published by authorized authorities, informing authorized persons, institutions, and organizations, ensuring that activities are carried out in accordance with legislation, following up and conducting legal affairs, carrying out financial and accounting operations,
• based on the legal ground that data processing is necessary for the establishment, exercise, or protection of a right; carrying out legal and litigation affairs,
• based on the legal ground that data processing is necessary for the legitimate interests of our company without prejudice to its fundamental rights and freedoms; carrying out activities aimed at developing and improving the services offered by our company,
• Based on the legal ground of having your explicit consent; transfer of personal data abroad,

your personal data is collected for.

7. To Whom and For What Purposes Processed Personal Data May Be Transferred

Your collected personal data may be transferred to our business partners, ESG Yazılım officials, company shareholders, and legally authorized public institutions and organizations within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, for the purposes of carrying out the necessary work by our business units to provide you with the services offered by ESG Yazılım, customizing and recommending ESG Yazılım's services according to your preferences and needs, ensuring the legal and commercial security of real and legal persons in business relations with ESG Yazılım, determining and implementing ESG Yazılım's commercial and business strategies, and ensuring the execution of ESG Yazılım's human resources activities.

Based on the legal grounds that data processing is necessary for the establishment, exercise, or protection of a right, is expressly provided for in the legislation to which our company is subject, and is necessary for the fulfillment of our legal obligations;

• Within the scope of fulfilling legal obligations, with lawyers, auditors, forensic IT specialists, cybersecurity consultants, tax consultants, and other third parties and business partners from whom we receive consultancy and services,
• With regulatory and supervisory bodies, and authorized public institutions and organizations such as courts and enforcement directorates,
• Your personal data may be shared with other public institutions or organizations authorized to request personal data, with our affiliates located domestically and/or abroad, with our suppliers, business partners, banks with which we have agreements, and third parties from whom we receive products or services.

As ESG Yazılım, some of your personal data may be transferred abroad to enhance your user experience and ensure the security of our platform. This transfer is carried out only based on your explicit consent within the scope of KVKK Article 9, or within the scope of commitments and standard contracts approved by the Board after determining countries with adequate protection, by taking the necessary security measures. The main situations and service providers for data transfer abroad are as follows:

• Through Google Analytics and Google Tag Manager services, your website visit data (cookies, browser type, session duration, etc.) may be transferred to countries abroad where Google LLC's servers are located.

These transfer transactions take place under the following conditions:

1. Limited only to the purpose of data processing and by taking the necessary technical/administrative security measures,
2. In accordance with Article 9 of KVKK, within the framework of data transfer agreements concluded with relevant service providers,
3. is carried out by obtaining your explicit consent.

As the data subject, you have the right to withdraw your explicit consent at any time. In case you withdraw your explicit consent, data transfer will be stopped immediately, and the destruction or anonymization of your existing data will be ensured.

8. Storage and Protection of Personal Data

Personal data collected orally, in writing, or electronically from applicants by ESG Yazılım units and offices, website, social media platforms, mobile applications, and similar means, is retained only for the period required by the purpose of personal data processing, or if no period is specified in the relevant legislation. Retained data is deleted, destroyed, or anonymized after the purpose of data processing ceases to exist.

ESG Yazılım is obliged to take all necessary technical and administrative measures against unauthorized access to, loss of, misuse of, disclosure of, alteration of, or unauthorized destruction of personal data collected from Applicants and all natural persons whose personal data has been processed by ESG Yazılım. Despite having taken all measures arising from the Law regarding the protection of personal data, ESG Yazılım shall not be held responsible for damages suffered by data owners due to circumstances such as cyber attacks that cannot be foreseen or prevented, system crashes, earthquakes, floods, fires, and severe damage to its servers due to force majeure events. Protective and preventive applications taken to protect your personal data,

• Penetration tests are performed periodically in accordance with international and national technical standards concerning data privacy.
• Your personal data transmitted to ESG Yazılım through the website, mobile site, and mobile application is protected using SSL (Secure Sockets Layer) technology.
• Risk analyses are regularly conducted for personal data processing activities, and actions are taken to mitigate risks.
• Access and authorization controls are applied to prevent unauthorized access to personal data.
• We inform you that we update our data processing policies at all times within this scope.

Stored personal data is deleted, destroyed, or anonymized in accordance with the Law and relevant legislation upon the cessation of the processing purpose or the expiration of the period stipulated in the relevant legislation. Some personal data may be stored for longer periods due to commercial, financial, and legal obligations. The storage periods of your personal data are determined within the scope of the Data Categorization and Storage Periods Policy, in line with the mandatory provisions of the legislation or for the duration required by the processing purpose.

In this context:

• According to the Turkish Commercial Code, commercial books and documents are kept for 10 years,
• According to the Tax Procedure Law, financial documents are kept for 5-10 years,
• Within the scope of other legal obligations such as consumer transactions, dispute records, invoice and payment data, data may be stored for the relevant statute of limitations period.

Upon the termination of these obligations, the relevant data is either destroyed or anonymized.

9. Keeping Personal Data Accurate and Up-to-Date

Pursuant to Article 4 of the Law, ESG Yazılım is obliged to keep the personal data collected from you accurate and up-to-date. You will be solely responsible for any inaccuracies or lack of updates in the personal data you have provided to ESG Yazılım verbally, in writing, or electronically through ESG Yazılım units and offices, website, social media channels, or similar means. You can make changes and/or updates to your personal data processed by ESG Yazılım through an application submitted to ESG Yazılım in electronic or physical form.

10. Rights of the Data Subject Arising from the Law

As personal data owners, if you submit your requests regarding your rights to ESG Yazılım through the methods described below, ESG Yazılım will finalize your request free of charge within a maximum of 30 (thirty) days, depending on the nature of the request. However, if a fee is foreseen by the Law and the Personal Data Protection Board, the fee specified in the tariff determined by ESG Yazılım will be charged to you. In this context, the rights of personal data owners pursuant to Article 11 of the Law are as follows:

• learning whether personal data is processed,
• Requesting information about whether personal data has been processed,
• Learning the purpose of personal data processing and whether it is used in accordance with its purpose,
• Obtaining information regarding third parties to whom personal data is transferred, domestically or internationally,
• Requesting correction of personal data if it is incomplete or inaccurate,
• Requesting the deletion or destruction of personal data if the reasons requiring its processing cease to exist, despite having been processed in accordance with the Law and other relevant legal provisions, and obtaining information about third parties to whom personal data has been transferred for the action to be taken in this regard,
• Objecting to a result arising to their detriment solely through the analysis of processed data by automated systems,
• To request compensation for damages in case of suffering damage due to the unlawful processing of personal data.

Pursuant to Article 13, Paragraph 1 of the Law, you may submit your request regarding the exercise of your rights specified above to ESG Yazılım in writing or through other methods determined or to be determined by the Personal Data Protection Board. Within this scope, the channels and procedures through which you can submit your applications to ESG Yazılım to exercise your rights under Article 11 of the Law are explained below.

Your request, including the necessary information to identify yourself and your statements regarding the right you wish to exercise, in order to exercise your rights explained above; the application form here doldurarak, formun imzalı bir nüshasını, kimliğinizi tespit edici belgeler ile bizzat elden veya noter aracılığıyla, kayıtlı elektronik posta adresi, güvenli elektronik imza, mobil imza ya da ilgili kişi tarafınca veri sorumlusuna daha önceden bildirilen ve veri sorumlusunun sisteminde kayıtlı olan elektronik posta adresi kullanılarak ve Kanun'da belirtilen diğer yöntemler ile iletebilirsiniz.

11. Information Regarding the Data Controller

ESG Yazılım Elektronik Arge Hizmetleri ve Otomasyon San. Tic. A.Ş., registered at Reşitpaşa Mah. Katar Cad. Arı 4 Binası No: 2 /50 / 6 Sarıyer/ İstanbul, with tax ID 3790849805, Tax Office SARIYER, is the Data Controller under the Law.

If deemed necessary, the Data Controller Representative to be appointed by ESG Yazılım will be announced in the Data Controllers' Registry and on the internet address where the Policy text is published.

12. Changes to the Privacy and Personal Data Protection Policy

ESG Yazılım reserves the right to amend this Policy text at any time. Amendments to the Policy text and the current Policy text will become effective immediately upon publication on the ESG Yazılım website. For this reason, it is recommended that everyone whose personal data is processed by ESG Yazılım, especially applicants, periodically review this Policy text.

13. Commercial Electronic Messages

If you have given your consent, we may offer you updates and offers for ESG Yazılım's services and campaigns through direct marketing methods (e.g., Phone, email, SMS, social networks, mail). Information regarding the Communication Management System ('IYS') will be provided after the creation of the relevant site, completion of infrastructure works, and the expiration of the period foreseen for registration in IYS.

Within this framework, we may use other personal data provided to us to determine our services, tailor them to your requests, and compile them; and to help us offer campaigns that may be of interest to you.

When we contact you as part of email, message, or other direct marketing activities, you are always presented with an "unsubscribe" option. You can change your marketing preferences by contacting us at any time.

Pursuant to Law No. 6563 on the Regulation of Electronic Commerce; records regarding the withdrawal of consent will be kept for 1 year from this date; all other records regarding the content of the commercial electronic message and its sending will be kept for 3 years to be submitted to the relevant ministry if necessary. After the period expires, your personal data will be deleted, destroyed, or anonymized by ESG Yazılım or upon your request.

When you visit our website, we automatically record your computer's IP address and browser signature.

ESG Yazılım Elektronik Arge Hizmetleri ve Otomasyon San. Tic. A.Ş.

Relevant Documents

KVKK Illumination Text  ·  Cookie Policy  ·  Terms of Use  ·  KVKK Application Form (PDF)